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          creates an unrealizable asset.  As a result, respondent argues              
          that the favorable financing intangible assets cannot be valued             
          separately, without looking at the value of the underlying                  
          mortgages.  According to respondent, petitioner’s valuation                 
          method results in overvaluation, double counting of assets, and             
          accounting irregularities because petitioner marks its                      
          liabilities to market without making the corresponding downward             
          adjustment to its assets.                                                   
                         a.   Favorable Financing Is an Asset                         
               Respondent’s contra-liability argument revisits the question           
          of whether favorable financing can be an amortizable asset.  We             
          have already rejected respondent’s argument that favorable                  
          financing is a liability.  See Fed. Home Loan Mortgage Corp. v.             
          Commissioner, 121 T.C. at 269, where we stated:                             
                    Respondent argues that petitioner’s favorable                     
               financing represents a “liability”, not an “asset”.                    
               Respondent claims that petitioner is “attempting to                    
               adjust, for tax purposes, the asset side of its balance                
               sheet to account for an overstatement in fair market                   
               value terms of its liabilities.”  We cannot agree with                 
               respondent’s proposed characterization of petitioner’s                 
               favorable financing as a liability.  Indeed, as                        
               petitioner points out, there is a valuable economic                    
               benefit associated with the below-market interest rates                
               on its financing arrangements as of January 1, 1985.                   
               It is this economic benefit which petitioner claims as                 
               an intangible asset and upon which it bases its claimed                
               amortization deductions.                                               
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